A practical workflow for documenting PPWR Article 5 PFAS evidence before food-contact packaging is placed on the EU market.
Use it to connect packaging scope, PFAS test evidence, supplier proof, and Annex VII technical documentation.
Structured answer sets in this page tree.
Cited legal and guidance references.
PPWR Article 5 makes PFAS evidence a packaging-specific conformity issue for food-contact packaging. The workflow should start with scope, then preserve the test results, supplier proof, role decisions, and technical-documentation links that show why a packaging item can or cannot proceed.
Do not run PFAS review as a generic packaging-waste checklist. First decide whether the item is food-contact packaging that will be placed on the EU market on or after the Article 5 PFAS date, then record the packaging type, component boundary, economic-operator role, and evidence owner.
If the packaging is not food-contact packaging, keep the scope note and route the item to the wider Article 5 substances-of-concern and heavy-metals checks. If it is food-contact packaging, move directly to PFAS concentration evidence.
For in-scope food-contact packaging, the evidence record should map each result to the Article 5(5) limit it supports. Keep the analytical method, sample identity, packaging component, result, unit, date, and reviewer together so the decision is reproducible.
The Article 5 limit structure is not a single yes-or-no PFAS claim. The record should separately cover targeted PFAS results, the sum of targeted PFAS results where applicable with prior degradation of precursors, and the broader PFAS value that includes polymeric PFAS.
Use this PPWR guide to connect food-contact packaging scope, PFAS concentration evidence, supplier proof, and Annex VII technical documentation.
The evidence workflow should make supplier data usable by the manufacturer or importer that has to maintain PPWR technical documentation. Keep supplier declarations, test reports, formulation notes, and total-fluorine proof linked to the exact packaging component and packaging type.
Article 5 compliance is demonstrated in Annex VII technical documentation, and suppliers must provide information and documentation needed for the manufacturer to demonstrate conformity. That makes the handoff a required operating control, not an optional procurement attachment.
Close the workflow with a clear release decision rather than a vague PFAS status. The decision should say whether Article 5(5) applies, which evidence was reviewed, whether any limit value is met or exceeded, whether total-fluorine proof was needed, and where the technical documentation is maintained.
Re-review the decision when packaging design, material composition, supplier, test evidence, Union restrictions, or the Commission's Article 5 evaluation changes. Article 5 also requires the Commission to evaluate whether the PFAS paragraph should be amended or repealed to avoid overlaps with other Union PFAS restrictions.
"PFAS will be banned from packaging from August 2026"
"changes in packaging design or in characteristics"